The SEC’s Division of Trading and Markets staff, recently, agreed to not recommend enforcement action, pursuant to Securities Exchange Act of 1934 Section 11(d) (1), if a broker-dealer receives payments in-kind to help defray the costs incurred in sponsoring educational and training seminars for a proposed ETF alliance program.

In granting the relief, the Staff noted the program did not generate any profit or income for the company.  No individual, apparently, would receive payment, and no activity would be tied to a sales contest or competition.  Further, the programs’ topics would arise from articles and speeches, and these would be product neutral.  All presentations would also be vetted and documentation would be maintained, among other things.

Essentially, if you neuter a sales program enough, the SEC Staff will allow just about anything.